Telehealth Policy & Resources
Medicare Telehealth Policy
Medicare telehealth policy shifted dramatically for the entire healthcare industry in response to COVID-19. Telehealth policy unique to RHCs and more broadly within the fee-for-service community evolved rapidly in a matter of months, expanding avenues for patients to see providers, but also creating unique hurdles that NARHC is working to fix.
RHCs were granted Medicare telehealth flexibilities shortly after the onset of the pandemic through a "special payment rule." The special payment rule reimburses RHCs and FQHCs through a composite system based on the weighted average of physician fee schedule codes billable via telehealth. Operationally, this means that RHCs and FQHCs use one single code, G2025, which pays one single rate, $94.45, for any and all of the over 280 services that are billable via telehealth. While this rule allows RHCs to serve as distant site providers for telehealth, it ultimately imposes significant barriers on safety-net providers seeking to offer telehealth services to their patients:- The payment rate is lower than an RHC’s all-inclusive rate, which disincentivizes investment in telehealth technologies;
- Limited data can be gathered from G2025 as it obscures and distorts claims data; and
- It requires RHCs to separate costs associated with telehealth on their cost report which generates significant administrative burden for the RHCs.
Further complicating the current policy landscape is the fact that in the 2022 Medicare Physician Fee Schedule, CMS changed the definition of an RHC/FQHC mental health encounter to allow mental health services provided via telehealth to be reimbursed through normal payment mechanisms. In other words, for mental health telehealth services, RHCs/FQHCs already have payment parity.
This so-called "temporary" special payment rule has remained in effect for over five years. As a result, RHCs have been operating without adequate telehealth reimbursement for an extended period, facing ongoing financial strain. Each short-term punt merely delays a long-term solution and extends the flawed special payment rule creating persistent uncertainty about the future of RHC telehealth services.
The timeline below illustrates the turbulent journey of telehealth flexibilities since 2020.
Telehealth Resources
Below are some resources to help RHCs navigate the shifting telehealth landscape. With any questions, please email Sarah Hohman at Sarah.Hohman@narhc.org.
- Beginning January 2022, RHCs can bill and be reimbursed for mental health services provided via telehealth. More information can be found here.
- Table 1 below breaks down the types of telehealth services RHC can bill for and how to bill for, including what was billable during the COVID-19 Public Health Emergency and the services’ temporary or permanent status. The majority of telehealth waivers will require further legislative action if they are to remain permanent.
- Table 2 below highlights the various Medicare telehealth waivers and their current status as of December 2025.
NARHC Telehealth Advocacy
NARHC is advocating for:
- Permanent coverage of medical telehealth encounters
- A revision of the RHC/FQHC payment policy to ensure that RHCs do not experience a disparity in reimbursement when seeing patients via telehealth
Bills introduced in the 119th Congress that achieve telehealth reimbursement parity for RHCs include:
- CONNECT for Health Act of 2025 (S.1261 and H.R. 4206)
- Save America's Rural Hospitals Act (H.R. 3684)
- Telehealth Modernization Act (H.R.5081)
- Helping Ensure Access to Local TeleHealth (HEALTH) Act (H.R.5496)
Make your voice heard on telehealth legislation here.
NARHC is also open to appropriate guardrails to ensure that the integrity of the telehealth benefit is protected in our safety net provider settings.
Table 1
|
Name of Telehealth Service |
Brief Description |
How to Bill |
Reimbursement Rate |
Relevant Dates |
|
Virtual Check-In or Virtual Care Communications |
Remote evaluation - G2010 Brief communication with patient (5 min) - G2012
|
G0071 052X |
2024: |
Permanent |
|
Digital e-Visits |
Online evaluation and management 99421-99423 |
G0071 |
2022: 2023: |
Only billable |
|
One to one substitutes or additions to in-person services/visits List of allowable services maintained by CMS |
G2025 Audio-only modifier: FQ Rev Code 052X Costs and encounters carved out of cost report |
2025: |
Billing details currently |
|
| Mental Health Telehealth Visits |
One to one substitutes or additions to in-person mental health services/visits CPT codes that can be billed with 0900 revenue code |
Rev Code 0900 Use proper mental health CPT code Modifier CG always Modifier 95 if audio-video Modifier FQ or 93 if audio-only |
All-Inclusive |
Permanent *Occasional in-person
|
| Chronic Care Management/ Principal Care Management/Remote Physiologic Monitoring/Remote Therapeutic Monitoring Psychiatric Care Management |
Care management and psychiatric care management.
|
G0323, 99487, 99490, 99491, 99424, 99426, G3002, G3003, 99453, 99454, 99457, 99458, 99091, 98975, 98976. 98977, 98980, 98981, G0019, G0022, G0023, and G0024 = G0511
99492, 99493 = G0512 |
Individual payment |
Beginning October 2025, RHCs |
| Transitional Care Management | Supporting the additional work provided to patients following discharge from an acute care setting to prevent errors and readmissions. | 99495, 99496 on an RHC claim, either alone or with other payable services | If it is the only medical service provided on that day with an RHC or FQHC practitioner it is paid as a stand-alone billable visit. If it is furnished on the same day as another visit, only one visit is paid. | Covered since January 1, 2013 |
Table 2
| Medicare Policy Area | Current Policy and Duration of Flexibility/Waiver |
| Originating Site/Geographic Requirements |
Patients receiving services from an RHC can receive telehealth services in their home through December 31, 2026. For any claims that were put on hold during the government shutdown period (October 1, 2025 - November 12, 2025), they will be paid retroactively from October 1st onward. |
| Distant Site Requirements | RHC providers can serve as telehealth distant site providers through December 31, 2026. |
| Billing/Cost Reporting Requirements | Please see table above. G2025 policy for medical telehealth visits remains in effect through December 31, 2026. |
| Modality | The Office of Civil Rights allowed for “non-public facing” remote communication products to be used for telehealth services, “exercising discretion” on stringent HIPAA compliant platform requirements. This ended on May 11, 2023. |
Other Telehealth Information of Interest
